The Centers for Medicare and Medicaid Services (CMS) recently posted its latest update to its sub-regulatory guidance for the SNF Mandatory Off-Cycle SNF Provider Enrollment Revalidation process. This update includes the following important change in regard to whether pharmacies, labs, x-ray suppliers, and nursing staffing companies must be disclosed as Additional Disclosable Parties (ADPs). See new Section (IV)(B)(2)) in underlined italics which reads:
2. Additional Information on ADP Disclosures
SNFs occasionally contract with pharmacies, labs, x-ray suppliers, and nursing staffing companies to help serve the SNF’s residents (e.g., the pharmacy provides drugs for the facility’s patients). Please note that for purposes of disclosure:
• Pharmacies, labs, and x-ray suppliers are not considered ADPs.
• Nursing staffing companies are considered ADPs under the “administrative services” category.
However, these companies need only be reported if the SNF has not yet submitted its revalidation application or SNF Attachment. If the SNF has submitted said revalidation/attachment, it need not revise its application to furnish this data.